DOS Adoption Notice: Department of State Designates Intercountry Adoption Accreditation and Maintenance Entity, Inc. as an Accrediting Entity UPDATED
From here:
“August 8, 2017
On July 28, 2017, the Department of State designated Intercountry Adoption Accreditation and Maintenance Entity, Inc., (IAAME) as an accrediting entity (AE) under the Intercountry Adoption Act of 2000 (IAA) in accordance with 22 CFR Part 96. The designation is for a period of five years.
IAAME is the second designated AE, joining the Council on Accreditation, whose designation was renewed July 11, 2016 for an additional five years. IAAME’s responsibilities as an AE will commence upon: 1) the Department of State’s approval of systems, procedures, and a fee schedule that will be coordinated as necessary to ensure consistency in accreditation systems and procedures used by both AEs; and 2) the Department of State’s determination of jurisdictional parameters.
The Office of Children’s Issues will provide additional information as it becomes available.”
From here:
“Q: Who is IAAME?
The Intercounty Adoption Accreditation and Maintenance Entity (IAAME) is a newly formed 501(c)(3) organization created for the sole purpose of the accreditation, approval, monitoring and oversight of adoption service providers providing intercounty adoption services. IAAME operates as a subsidiary of Service Management Solutions for Children, Inc., and shares leadership with the Partnership for Strong Families (PSF), the lead agency for child welfare services in Florida Circuits 3 and 8. IAAME will be led by the Intercountry Adoption Accreditation Director, Ms. Kim Loughe. The Director will serve as the liaison between IAAME and the Department of State and will provide oversight and leadership of all transition plans and operationalization activities.
Key IAAME personnel involved in intercountry adoption accreditation, approval, monitoring, and oversight will be:
Stephen Pennypacker – President/CEO
Stephen Pennypacker, Esq., joined PSF as President and CEO in April 2014. Mr. Pennypacker has more than 19 years’ experience working in child welfare as an attorney and administrator and most recently served as Assistant Secretary for Programs for the Florida Department of Children and Families (DCF.) In this role, his duties included oversight of policy development, rule-making and maintenance of programs for adoptions, domestic violence, foster care, adult protection, homelessness, child care licensing, background screening, federal compliance, federal grants, quality assurance and contract management for Florida’s child protection system. He managed a multi-million dollar budget and worked regularly with the Legislature and the Governor’s office.
Prior to this role, Mr. Pennypacker was the national president for the Interstate Compact for the Placement of Children, served as a Deputy Director for Children’s Legal Services and presided as General Magistrate for the Eighth Judicial Circuit in Florida. He also worked for the Florida State Attorney’s office at the time DCF began to privatize, managed the local pilot project for Children’s Legal Services, and spent 15 years in private practice prior to concentrating his career in child welfare. Mr. Pennypacker is a graduate of P.K. Yonge Developmental Research School and went on to receive a Bachelor’s in Political Science from Duke University. He returned to Gainesville to attend law school at the University of Florida, where he remains an Adjunct Professor today teaching adoption law.
Michael Reneke – CFO
Michael Reneke was named CFO for PSF in 2015. Mr. Reneke joined PSF as a Senior Contract Manager in 2005, becoming Director of Special Services in 2007. He was promoted to Senior Vice President of Finance and Administration in 2010 and added oversight of PSF’s Information Technology, Finance, and Risk Management to his responsibilities in Contract Management and Quality Assurance.
Mr. Reneke’s 22 year work history in children services includes public sector experience as a Senior Public Assistance Specialist and a Grants Analyst with the State of Florida’s Department of Children and Families. He also served with the Agency for Workforce Innovation, where he designed contracting and financial practices and worked extensively with local boards on the design and implementation of their own unique systems. He helped design the audit and monitoring practices still being used by the State of Florida today and conducted audits throughout the state. Mr. Reneke also has experience working with Early Learning Coalitions, collaborating with the Florida Legislature’s Office of Program Policy Analysis and Government Accountability, participating in legislative reviews, and working with the Office of the Inspector General. He has a Bachelor of Arts degree from the University of West Florida.
Kim Loughe – Intercountry Adoption Accreditation Director
Kim Loughe, employed with Partnership for Strong Families since 2004, will serve as IAAME’s Intercountry Adoption Accreditation Director. Ms. Loughe has 24 years working within DCF and the private child mental health and child welfare arenas. Early in her career, Ms. Loughe worked as a Case Manager with a local community mental health provider, working with children in need of psychiatric residential treatment. She began working with the Florida Department of Children and Families (DCF) in 1988 as a Public Assistance Specialist, progressing to Foster Care Counselor working with children in the dependency system within the foster care unit to address safety, well-being, and permanency, and later served as a Senior Human Service Specialist in the Substance Abuse and Mental Health Program Office. Ms. Loughe is certified by DCF and is a Safety Practice Expert for the Florida Decision Making Methodology and is currently PSF’s Director of Program Quality and Contract Management. She has a Bachelor’s Degree in sociology from the University of Florida.
Q: What qualifies IAAME to be a designated AE?
IAAME is a designated AE under the IAA and 22 CFR 96.5 as “an organization described in section 501(c)(3) of the Internal Revenue Code of 1986, as amended, that has expertise in developing and administering standards for entities providing child welfare services.” Although IAAME is a newly formed organization, it is operated by staff with extensive experience in providing child welfare services, administering child welfare standards, contracting, licensing, monitoring, and domestic adoption services. Through an extensive review process, the Department determined IAAME meets the eligibility requirements under Section 202(a)(2) of the IAA and 22 CFR 96.5 and demonstrates the capacity to perform AE duties as required by the IAA and the UAA.
Q: How can I communicate with IAAME?
IAAME’s AE responsibilities have not yet commenced. Accredited adoption service providers should continue to interact with the Council on Accreditation (COA) regarding all accreditation matters. Questions about IAAME may be directed to the Office of Children’s Issues by email to Adoption@state.gov.
Q: Why did the Department designate a second AE?
22 CFR 96.4 authorizes the Department to designate more than one AE and to impose limits on an AE’s jurisdiction. The Department has designated multiple AEs in the past. From 2008- 2013, both COA and the Colorado Department of Human Services (DHS) were designated AEs. The Department periodically issues a Request for Statements of Interest (RSI) to become a designated AE in order to offer eligible organizations the opportunity to take on this important role. An RSI issued in 2013, in preparation for the implementation of the Universal Accreditation Act (UAA) did not result in the designation of additional AEs. The Department was pleased to receive submissions from multiple organizations in response to the March 31, 2017, RSI and believes the designation of multiple AEs will provide opportunities for collaboration that will enhance each organization’s execution of AE duties and responsibilities.
Q: Is COA still an AE?
Yes, the Department renewed COA’s designation as an AE on July 11, 2016, for a period of five years, and is pleased to continue its working relationship with COA.
Q: How will AE jurisdiction be divided between IAAME and COA?
This will be determined by the Department, in consultation with IAAME and COA. The Department will notify ASPs and the public about jurisdictional decisions as soon as possible thereafter.
Q: When will IAAME begin acting as an AE?
IAAME’s responsibilities as an AE will commence upon: 1) the Department of State’s approval of systems, procedures, and a fee schedule that will be coordinated as necessary to ensure consistency in accreditation systems and procedures used by both AEs; and 2) the Department of State’s determination of jurisdictional parameters.
Q: For ASPs due for renewal of accreditation next year, which AE will they work with?
The AEs and the Department will have a series of meetings in the coming months to align processes. Until further notice, accredited ASPs should continue to work with COA on all accreditation, approval, monitoring, and oversight matters.
Q: I just paid all my accreditation fees to COA; what happens if I’m transferred to work with IAAME?
As the Department identifies jurisdictions for each AE, there will be further discussion about transfer of fees, cases, records, and other matters relevant to ASPs who will be working with IAAME. The Department will notify and provide guidance directly to affected ASPs.
Q: I am a FL based agency. Does this mean I will automatically be working with IAAME?
Not necessarily. The Department has not made any decisions about jurisdiction for the AEs.”
REFORM Puzzle Piece
Update: From here:”Adoption Notice: IAAME Fee Schedule, Explanation, and FAQ
Fee Schedule for Accreditation, Monitoring and Oversight
In accordance with the regulations pertaining to the accreditation and approval of adoption service providers (ASPs) in the United States, the Department has approved the Intercountry Adoption Accreditation and Maintenance Entity, Inc.’s (IAAME) fee schedule, which will be implemented as IAAME begins to assume its responsibilities as a designated accrediting entity (AE). Under 22 CFR 96.8(b), an AE’s schedule of fees must include “the costs of all activities associated with the accreditation or approval cycle, including but not limited to, costs for completing the accreditation or approval process, complaint review and investigation, routine oversight and enforcement, and other data collection and reporting activities …”. Accordingly, IAAME will charge fees as described in its fee schedule.
Since IAAME’s designation as an AE and the Council on Accreditation’s (COA) decision to withdraw, the Department has heard from many ASPs and other adoption stakeholders regarding concerns about how the transition might impact ASPs, particularly with regard to potential changes in fees. A specific concern has been that smaller ASPs, or those that only do home studies, might face economic difficulties if fees increase.
Following the designation of IAAME as an accrediting entity, the Department and the two designated accrediting entities met to align processes. Part of that discussion related to the alignment of fee schedules. In preparation for the alignment, the Department reviewed the current and potential fee structures and explored ways to improve AE oversight with the smallest possible financial impact on ASPs and adoptive families. Available information indicated that smaller agencies may have paid a disproportionate share of the cost of activities associated with the accreditation and approval cycle, and that under some models, fees did not equitably accrue to the agencies and persons performing the largest number of adoptions, which generate greater costs to the AE. Therefore, the Department encouraged the accrediting entities to adopt fee structures that would more equitably distribute fees, while also ensuring that AE fees do not exceed the full costs of all activities associated with accreditation and approval of ASPs. These conversations continued after COA notified the Department of its decision to withdraw as an accrediting entity.
As we have noted in conference calls and other communications with ASPs, as IAAME developed its proposed fee schedule, the Department requested it adhere to the following objectives:
- The fee structure must be sufficient to recover the full costs of activities associated with accreditation and approval that the AE is required to perform, pursuant to the accreditation regulations.
- The fee schedule should be fair and equitable to all ASPs and prospective adoptive families.
- The fee schedule should accurately reflect the AE’s work required to execute its responsibilities, e.g. where more work is required to accredit or monitor and oversee an ASP, the fees should reflect the higher costs associated with the additional work; similarly, fees should reflect lower costs where less work is required.
The Department approved IAAME’s fee schedule and is pleased it clearly meets both the requested and required parameters. IAAME’s approach to separate fees associated with the accreditation/approval/renewal processes (accreditation) and those associated with monitoring and oversight (M&O) facilitates an equitable fee distribution across all ASPs, according to size and number of cases, and reflects the need for increased focus in the area of M&O.
Under previous structures, the M&O fee was the same for agencies and persons of all sizes and accreditation fees, which are charged at a flat rate, were based on the revenue of the agency or person. Under this model, the lowest combined fees paid over a four year cycle were $11,900, and the largest fee was $18,250 regardless of the number of adoptions an agency performed.
Under the new model, accreditation fees charged at a flat rate for four years to cover the actual costs of accreditation are based on the number of cases in which an agency or person serves as the primary provider. M&O fees are charged to primary providers on a per case basis. This allows IAAME to keep the set cost of accreditation services at a lower level, and to recoup higher costs for M & O fees based on the number of cases an agency or person performs. Under this model, the higher fees accrue to those agencies that process the highest number of cases. Under IAAME’s model, the lowest combined fee paid over a four year cycle will be $8800, a likely decrease of over 25% for the smallest and home study only agencies.
For this reason, the Department expects many ASPs will experience a fee decrease as a result of the tiered fee structure based on the average number of cases in which the ASP acted as the primary provider in the previous two years. Currently, the Department estimates that a majority of ASPs handle fewer than 15 adoptions per year, and compared to larger ASPs, they operate in fewer countries and have fewer staff. Thus their accreditation process is more streamlined and requires less AE time when compared to agencies with multiple country programs, multiple offices, and many employees. The Department considers this structure to be reasonable and equitable.
Similarly, IAAME’s fee structure for M&O is designed to reflect the proportionate nature of M&O activity across all ASPs by introducing a per case model that acknowledges the AE conducts more work to monitor and oversee ASPs with higher caseloads. It’s important to note the M&O fee is not charged in advance, but is payable as an ASP accepts new intercountry adoption applications. These fees of $500 per case are paid once, not annually, and will likely become part of the fees required of prospective adoptive parents rather than being added to the ASP’s overhead costs. The Department estimates, based on the average cost of adoptions reflected in ASP reporting in the Adoption Tracking System, that the increase in costs to families should be approximately 1.4%.
IAAME’s policy and procedure manual, once published, will include more information for ASPs regarding the operational aspects of implementing the fee schedule, including how cases will be recorded and reported. IAAME’s fee schedule, along with an explanation of fees and FAQ regarding the schedule and it structure, are included below and will shortly be available on www.IAAME.net.
Intercountry Adoption Accreditation and Maintenance Entity Fee Schedule
| Fee Category | Amount |
| Initial Accreditation/Approval Application Fee | $3,000 |
| Accreditation/Approval Renewal Application Fee | $800 |
| Extension Fee | $2000 |
| Accreditation/Approval Fee | 0-5 Adoptions = $8,000
6-25 Adoptions = $12,000 26-75 Adoptions = $16,000 76+ Adoptions = $20,000 |
| Monitoring and Oversight Fees | $500 per adoption |
| Site Visit Fees (including site visits conducted for complaints and/or adverse action) | Travel Costs – actual cost of transportation per reviewer (plane ticket, gas, rental car, train)
Per Diem costs per reviewer – IAAME will apply current federal per diem rates per reviewer per day of site visit activities |
| Site Visit Rescheduling Fee | $1,000 plus actual cost of changes to transportation and lodging charges |
| Certificate Replacement Fee | $5 per certificate requested |
All fees are non-refundable
Details related to IAAME’s fees and fee collection are found in the IAAME policy and procedure manual”
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